Subject: Public Input Welcomed on Climate Change Disclosures (March 15, 2021)
From: Sibyl OMalley
Affiliation:

Jun. 11, 2021

 

• The SEC should develop a comprehensive framework to help ensure that companies report more consistent, complete and comparable information relevant to their long-term risks, opportunities and performance. 

•. Voluntary reporting leads to significant data gaps, especially among medium and small companies. 

• ESG disclosure must be mandatory for all reporting issuers in the United States. 

• ESG disclosure must have comprehensive information to allow investors to gain a holistic understanding of company practices. 

• ESG Disclosures should allow comparisons among organizations within sectors, regions, industries or portfolios. 

• Harmonize, where possible, with existing international standards to prevent comparability mismatches that leave the information generated less useful for investors framework should be designed to evolve in a timely manner as new issues emerge. 

• Climate risk is not currently priced by financial markets because people don’t have the information they need to assess physical risk. 

• Human capital disclosures should at minimum require EEO-1 reports, pay gap ratios for all demographics, employee turnover and composition of the workforce.